Privacy Policy

1. How We Collect and Use Personal Information

We collect Personal Information from you for specific and limited purposes, where you consent to the collection, in order to meet our contractual commitments to you and to comply with our legal obligations. When collecting Personal Information from you, we will identify the purpose for collecting your Personal Information at the time we request it and will not use or disclose your Personal Information other than for the purpose for which it was collected, without your prior consent or as otherwise permitted by applicable data protection and privacy laws. We endeavor to collect the minimum amount of Personal Information required to fulfil the purpose for which it was collected.

If you chose to withhold any Personal Information requested by us or withdraw your consent, it may not be possible for us to provide the Services to you or respond to your query.

We collect and use your Personal Information in a variety of ways, including for the following purposes:

• Providing Services and Sharing Information. Your Personal Information may be collected and used by Sitka to provide Services to you or via our Sites, or otherwise. Your Personal Information may be used by Sitka so that we can share information about Sitka, the Sites and our Services with you and to maintain appropriate records for our internal administrative purposes. We may use your Personal Information to communicate with inquiries for information, employment opportunities or other issues as they relate to your use of the Sites and the Services.
• Polls and Surveys. We may conduct polls and surveys to understand interests and topics of relevance in specific regions. If you choose to participate, we collect the information you provide in your responses, along with any optional demographic or location information you choose to share. We use this information to analyze trends, understand audience interests, and tailor content to particular topics or regions. Poll and survey responses are analyzed in aggregate form. We do not use your responses to identify you personally unless you voluntarily provide identifying information. Participation is voluntary, and you may decline to answer any question.
• Contests. We may offer contests where we collect the Personal Information necessary to administer the contest, including verifying entrants' eligibility, and contacting winners. Personal Information provided may include your name, contact information, and any responses submitted as part of the entry process. We may also use aggregated, non-identifying information from contest entries to help understand audience interests and tailor content to specific interests or areas.
• Protection Purposes. We may also use your Personal Information to detect, prevent or investigate security breaches or fraud, to protect our business and to maintain appropriate records for internal administrative purposes, including analyzing and monitoring usage of our Sites.
• Service Analysis, Automated Collection. We automatically record certain information when you use our Sites. We may use permanent cookies or server-side artifacts to help us track use of our services by users, including casual visitors to the Sites — such as (without limitation) the number and frequency of visits to our pages and which parts of our Sites are visited.

Wherever you have given us your consent to use your Personal Information, you may withdraw your consent at any time by contacting our Privacy Officer at contact@sitkamedia.ca. You may no longer be able to access some or all of our Sites or the Services if you withdraw your consent.

2. Our Disclosure of Personal Information

Sitka may disclose your Personal Information with your express consent, for debt collection purposes, for loss or fraud prevention purposes or for Sitka's other legitimate interests. Sitka may further disclose Personal Information if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so. We will use reasonable efforts to ensure that any third party to whom Personal Information is disclosed provides a comparable level of protection for your Personal Information, as provided in this Privacy Policy.

We may share Personal Information with our affiliates for the purposes described in this Privacy Policy, such as analyzing audience interests, tailoring content, improving our services, and supporting business operations. Affiliates may include companies under common ownership or control, such as related media outlets or digital platforms. Affiliates may use this information only for the purposes for which it was originally collected, unless you provide additional consent. You may withdraw your consent to the sharing of your Personal Information with affiliates at any time by contacting our Privacy Officer at contact@sitkamedia.ca.

We also share some of your Personal Information with third parties in order to offer the Services to you, including sending information to third party service providers that help us to operate our Sites including website hosting, data analysis, event logging, information technology, customer service, user analytics, and email delivery and messaging. We will further share your Personal Information with third party providers of marketing services who will assist us with promotional services.

Additionally, Sitka reserves the right to disclose and to transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, merger, amalgamation, or any other type of acquisition, disposition, or financing of all or any portion of Sitka or any of the assets or shares of Sitka, provided that the third party represents that it will continue to use the information for the purposes set out in this Privacy Policy and in accordance with applicable privacy laws. Sitka also reserves the right to aggregate and anonymize Personal Information (or other information) stored on its system and use such aggregated and anonymized Personal Information (or other information) as it sees fit.

3. Consent

It is important to us that we collect, use or disclose your Personal Information only where we have your consent to do so or as provided in this Policy. Depending on the sensitivity of the Personal Information, your consent may be express, implied or deemed. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you contact us about our Services, we will assume your consent to the collection, use and disclosure of your Personal Information for purposes related to your request or for other purposes identified to you at the relevant time. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you.

By submitting your Personal Information to us or obtaining our Services, you consent to the collection, use and disclosure of your Personal Information in the manner described in this Policy. To the extent that we are required by applicable laws to obtain your explicit consent for the collection, use or disclosure of your Personal Information in accordance with this Policy, such consent will be requested at the appropriate time. Further, if we plan to use or disclose your Personal Information for a purpose not previously identified (either in this Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure. However, we may collect, use or disclose your Personal Information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Privacy Officer using the contact information set out below. In some circumstances, a change or withdrawal of consent may limit our ability to provide Services to you or your ability to access certain areas of our Sites.

We assume, unless you advise us otherwise, that by receiving a copy of this Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of your Personal Information as explained in this Policy.

4. Retention of Personal Information

We routinely destroy Personal Information that is no longer required for the purposes for which it was collected, in accordance with applicable laws.

5. Accuracy of Personal Information

Sitka takes reasonable steps to ensure that any Personal Information in our custody is accurate and up to date for the purposes for which the Personal Information is to be used by Sitka. In most instances, we rely on users of our Services to notify us of any changes to their Personal Information provided by them.

6. How We Protect Your Personal Information

Sitka uses reasonable and appropriate measures, including encryption software, designed to help you secure your Personal Information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the Personal Information collected by us are authorized to do so. Unauthorized use of Personal Information by anyone affiliated with Sitka is prohibited and constitutes grounds for disciplinary action.

Sitka is not responsible for any failure by you to secure your own device and its access to the Internet or your use of public, unsecured networks. Sitka also is not responsible for any failure by you to eliminate malware. These failures and others can make you vulnerable to privacy breaches and would put you and your data at risk.

7. Location of Personal Information

Personal information we collect is stored and processed by us and our third party service providers primarily in Canada, regardless of where you are located.

8. Links to Third Party Sites

The use of our Sites may lead you to third party websites. Those organizations are separate and distinct from Sitka and have their own separate privacy policies. We are not responsible in any way for how any third party collects, uses or discloses your Personal Information, so it is important to familiarize yourself with the privacy policies of these websites before providing your Personal Information to them.

9. Cookies and Similar Technologies

In order to improve our Sites on an ongoing basis, we use cookies to track your visit. The Sites also use cookies to provide users with certain features and preference settings.

A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the website that gave it to you. It functions as your identification card. It is not a program and cannot be executed as code or deliver viruses.

Cookies can also customize the site to your particular interests or store your Personal Information — like passwords or user IDs. If a site ever greets you with your name, chances are it's using a cookie to do so.

Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie — this gives you the chance to decide whether to accept it. To learn more about cookies and how to change your settings, please use the help function in your browser.

You can use the Sites without cookies, but you may have to re-enter information each time you visit. When you visit our Sites, Google Analytics adds a cookie to distinguish you from other users and track your behaviour across our Sites. We use this information to improve the user experience of the Sites. The cookie lasts for up to 2 years. You can read about this in the Google Analytics Privacy Policy.

With your permission, our Sites use the Conversion Tracking service provided by Meta Platforms, Inc. ("Meta"). This tool allows us to understand how users interact with our Sites after clicking on a Facebook advertisement and to measure the effectiveness of our advertising for statistical and market research purposes. We do not receive any information that personally identifies individual users. However, the data collected may be stored and processed by Meta, which may associate it with your Meta account and use it for its own advertising purposes, in accordance with Meta's Data Policy.

You may revoke consent for personalized advertising at any time by adjusting your settings at facebook.com/adpreferences/ad_settings. Users who do not have a Facebook account may opt out of interest-based advertising through the industry-wide tool at optout.aboutads.info.

Similarly, we may also collect information regarding the type of device, your operating system, the browser you use, your internet service provider, your domain name, your internet protocol (IP) address, the date and time that you accessed our service, the website that referred you to one of our Sites, the web pages you requested and the subject of the ads you click or scroll over, and use such information to evaluate service performance and service quality and to optimize the user's experience of our Sites. To collect this information, we use cookies, web beacons and similar technologies.

10. Direct Marketing

We are committed to complying with Canada's Anti-Spam Legislation. Where we have your consent or it is lawful to do so, we may provide you with direct marketing communications about our Services which may be of interest to you. Such information may be sent to you by post, email, telephone or SMS.

You may sign up to receive marketing or promotional communications from us. Where you have opted in, we may use your Personal Information to inform you about us and our services, including promotional offers and events.

If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:

• using the unsubscribe feature found in our emails and other electronic communications; or
• contacting us via email at contact@sitkamedia.ca.

11. Your Rights

Upon written request to our Privacy Officer at contact@sitkamedia.ca, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to that Personal Information. Sitka provides an opportunity for individuals to challenge the accuracy and completeness of their Personal Information and have it amended as appropriate.

12. Contacting Us

Accountability with respect to your Personal Information is important to Sitka. In the event that you have any questions (including how Personal Information is managed by Sitka), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our Privacy Officer at contact@sitkamedia.ca.